Who is required to have a DQ file?

The driver’s qualification (DQ) file is often thought to go hand-in-hand with the commercial driver’s license (CDL). This has created confusion for many carriers. For interstate drivers, the need for a DQ file is based on the size and type of vehicle being driven. The applicable definition of commercial motor vehicle includes both CDL and non-CDL drivers alike. Intrastate drivers would need to look at state-specific regulations to determine applicability.

Drivers operating the following vehicles in interstate commerce need to have a completed DQ file:

• Vehicles with a gross vehicle weight (GVW) or gross vehicle weight rating (GVWR), or gross combination weight (GCW) or gross combination weight rating (GCWR) of 10,001 pounds or more; or
• Vehicles designed to transport more than 8 people (including the driver) for compensation, or more than 15 people (including the driver) not for compensation; or
• Vehicles transporting hazardous materials that require the vehicle to be placarded.

The criterion in this definition that causes most confusion is the vehicle weight. The general weight criterion for which a CDL is needed is 26,001 pounds. The weight criterion for which a DQ file is needed is 10,001 pounds. So, interstate drivers of vehicles between 10,001 and 26,001 pounds (not hauling hazmat) need to have a DQ file but do not generally need to have a CDL.

For intrastate drivers, it depends on what the state has adopted for the weight criterion. A number of states use the same 10,001 pound criterion as is found in the Federal Motor Carrier Safety Regulations. Other states have increased the weight limit to anywhere from 12,000 pounds up to 26,001 pounds (which does coincide with the CDL requirements). A few states also have grandfather clauses or other exemptions that may except certain drivers from certain portions of the DQ file, such as medical cards.